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4%� <br /> Thrifty Oil Company#171 page 2 <br /> 1250 N. Wilson Way, Stockton CA May 4, 2010 <br /> 106,000 micrograms per liter (ug/1). Groundwater concentrations of dissolved TPHg since the <br /> 2008/2009 GWE test have dropped significantly. The last concentration of TPHg noted on <br /> Geotracker is from the December 2009 sampling event and lists the highest TPHg groundwater <br /> concentration at 31,600 ug/I from monitoring/extraction well EW-5D. The other two wells <br /> located in the dissolved contaminant plume and proposed as groundwater extraction points, <br /> EW-5S and TB-7, reported TPHg at 1,610 ugll and 6,600 ug/l, respectively for the same <br /> sampling event. The EHD has concerns that extracting groundwater from these three wells at a <br /> combined extraction rate of 0.3 gpm may not be as effective against the mass as TOC has <br /> concluded. <br /> The EHD requires that a pilot groundwater extraction test be conducted utilizing the parameters <br /> included in the FS-WP. A full scale GWE action from all the wells proposed should be <br /> conducted for an adequate time to gather sufficient data to support conclusions that this GWE <br /> rate and treatment will reduce the contamination at the site in the time estimated by TOC. The <br /> report of findings should include an evaluation of the mass removal rate compared to the total <br /> residual mass. <br /> A work plan for the GWE pilot test is to be submitted to Geotracker by June 30, 2010. The <br /> complete FS-WP evaluation and approval is on hold and pending results of the GWE pilot test. <br /> If you have any questions, please contact Michael Infurna at (209)468-3454. <br /> 71 <br /> Michael J. Infuma Jr., REHS Nuel C. Henderson Jr., PG <br /> Senior Registered Environmental Health Specialist Engineering Geologist <br /> c: Mr. James L. Barton, CVRWQCB, Underground Storage Tank Unit, 11020 Sun Center <br /> Drive, #200, Rancho Cordova, CA 95670-6114 <br /> Mr. Mark Owens, SWRCB, Division of Clean Water Programs, Underground Storage <br /> Tank Program, P.O. Box 944212, Sacramento, CA 94244-2120 <br />